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Are Northwest Dams Being Set Up To Fail? by Kurt Miller The Daily News, June 22, 2020

Pacific Northwest National Laboratory identified air temperature and flow levels
as the biggest influences on temperatures in the river.

The future of low-cost, carbon-free hydropower in the Northwest is in jeopardy. Due to recent regulatory developments in Oregon and Washington, and at the federal level, dam operators are facing new and unattainable rules that put the hydro system at risk.

A report released by the EPA on May 18 entitled "Total Maximum Daily Load (TMDL) for Temperature in the Columbia and Lower Snake Rivers" outlines river temperature limits and seeks public comment. The report is related to a recent decision by the states of Washington and Oregon to require a river temperature provision as part of an EPA permit for federally operated Columbia River Basin dams.

This is a complex issue involving multi-jurisdictional laws, but it has already been used as a reason by anti-hydropower groups to call for breaching the lower Snake River dams. That call could easily impact the lower Columbia River dams as well.

However, there's a major problem with breaching dams to reach the new water quality standards.

While the EPA used a model to attempt to estimate the effect of dams on river temperatures, it took actual temperature measurements of water coming in from Canada and Idaho. The TMDL report clearly demonstrates that water entering the U.S. from Canada is already too warm "by a substantial margin" to meet the Washington state standard in the summer months.

The same is true for water entering the lower Snake River dams from Idaho. In fact, Idaho participated in developing similar guidance with the EPA for the Snake River in 2003, but in the end, Idaho dissented due to reservations about attainability. According to the Idaho Dept of Environmental Quality website, "these reservations persist to this day."

Given these conditions, the EPA notes the significant challenge of meeting the new water quality standards in Washington and Oregon and has suggested that the states reconsider their respective standards.

Additionally, highly reputable studies have shown that dams help mitigate summer temperature extremes: a 2002 peer-reviewed study by Pacific Northwest National Laboratory showed that dams within the Columbia and Snake river basins moderate extreme water temperatures by shifting some of the summer heat into the fall and thereby flattening the temperature curve. The study refers to this phenomenon as a thermal inertia effect.

Again in 2002, researchers compared pre-lower Snake River dam measurements of water temperature from 1955-1958 to measurements taken after the dams were constructed. They found no evidence that river temperatures had increased as a result of the dams, and instead appeared to have remained unchanged or slightly lower, even though air temperatures had increased.

The team identified air temperature and flow levels as the biggest influences on temperatures in the river.

River temperatures are a significant concern for salmon in both dammed and undammed rivers. In 1994, due to record high temperatures, approximately 466,000 adult fish perished in the undammed Fraser River before reaching their spawning grounds. In 2015, a quarter of a million Snake River sockeye salmon died during a heatwave. Large fish die-offs were also recorded in Alaska's undammed rivers last summer due to heatwaves.

The problem with taking an excessive and unrealistic regulatory approach is that, in the extreme, it could add billions of dollars to the cost of operating the hydroelectric system without actually helping salmon.

It could also add excess costs to communities who rely on the low cost of hydropower to make ends meet -- especially now that residential customers in the Northwest are facing a financial crisis, and residential energy consumption is rising due to the constraints of the pandemic.

This newly proposed burden for regional hydropower operators feels unrealistic, unworkable, and unfair to the communities that depend on affordable hydroelectricity to help make ends meet. It seems as if the dams are being set up to fail.

We encourage everyone to submit their comments to ColumbiaRiverTMDL@epa.gov, by 5:00pm PT on July 21, 2020.

Related Pages:
Do Dams Really Impact River Temps in the Columbia/Snake Rivers? Here's the Science. by Kurt Miller, The Daily News, 5/23/20
Vulnerable Communities Need Low-Cost Energy by Kurt Miller, The Register-Guard, 5/22/20
Public Meetings on the Dams End Successfully After Digital Pivot by Kurt Miller & Scott Rhees, Tri-City Herald, 4/10/20
We Can Improve Conditions for Salmon and Orcas without Destroying Snake River Dams by Kurt Miller, Statesman Journal, 2/21/20
Get Rid of Dams to Save Salmon? Not So Fast by Kurt Miller, Idaho Statesman, 10/1/19
A Tale of Two Salmon Conferences by Kurt Miller, Post Register, 7/26/19